COMMENT FORM

Maureen Long

Informations

• Publié par: Vawyor
• Nombre de lectures: 70
• Langue: English

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Comment Form — Proposed Violation Risk Factor SAR
Comment Form
Proposed Violation Risk Factor SAR

This form is to be used to submit comments on the proposed Violation Risk Factor
Standard Authorization Request (SAR). Comments must be submitted by March 6,
2006. You may submit the completed form by e-mailing it to: [e-mail]
with the words “Violation Risk Factor SAR Comments” in the subject line. If you have
questions please contact Mark Ladrow at [e-mail] or by telephone at
609-452-8060.

ALL DATA ON THIS FORM WILL BE TRANSFERRED
AUTOMATICALLY TO A DATABASE. IT IS THEREFORE
IMPORTANT TO ADHERE TO THE FOLLOWING REQUIREMENTS:

DO: Do enter text only, with no formatting or styles added.
Do use punctuation and capitalization as needed (except quotations).
Do use more than one form if responses do not fit in the spaces provided.
Do submit any formatted text or markups in a separate WORD file.


DO NOT: Do not insert tabs or paragraph returns in any data field. use numbering or bullets in any data field.
Do not use quotation marks in any data field. submit a response in an unprotected copy of this form.

Individual Commenter Information
(Complete this page for comments from one organization or individual.)
Name: Ron Falsetti
Organization: IESO
Telephone: [phone]
E-mail: [e-mail]
NERC Registered Ballot Body Segment
Region
ERCOT 1 — Transmission Owners
FRCC 2 — RTOs, ISOs, Regional Reliability Councils
MRO 3 — Load-serving Entities
NPCC 4 — Transmission-dependent Utilities
RFC 5 — Electric Generators
SERC 6 — Electricity Brokers, Aggregators, and Marketers
SPP
7 — Large Electricity End Users
WECC
8 — Small Electricity End Users
NA — Not
9 — Federal, State, Provincial Regulatory or other Government Entities Applicable


Page 1 of 8 Comment Form — Proposed Violation Risk Factor SAR

Group Comments (Complete this page if comments are from a group.)
Group Name:
Lead Contact:
Contact Organization:
Contact Segment:
Contact Telephone:
Contact E-mail:
Additional Member Name Additional Member Region* Segment*
Organization
























*If more than one region or segment applies, indicate the best fit for the purpose of
these comments. Regional acronyms and segment numbers are shown on prior page.
Page 2 of 8 Comment Form — Proposed Violation Risk Factor SAR
Background Information:
As NERC moves forward to become the Electric Reliability Organization (ERO) and
enforcement of the NERC reliability standards and the requirements contained within
begins, there will be a need to determine and specify the relative risk the violation of
each requirement poses to the bulk electric system. The requester proposes to
develop, through the NERC standards development process, a matrix (Violation Risk
Matrix) delineating the relative risks associated with the violation of each NERC
standard requirement. This Violation Risk Matrix would be used for the initial basis for
determining enforcement action for future violations. The requestor recognizes the
current Reliability Standards Process Manual does not envision the use of this type of
matrix, but if the consensus of the stakeholders approves the concept, a SAR would be
initiated to make any required changes to the manual. Although significant additional
information is provided below, the requester respectfully requests the comments
included in response to this SAR be limited to the scope of the Violation Risk Factor
SAR realizing additional comment time will be allotted with future posting as the
content of the matrix is developed.

The definitions used for the purposes of rating each of the requirements are:

High Risk Requirement
a. A requirement that, if violated, could directly cause or contribute to bulk
electric system instability, separation, or a cascading sequence of failures, or
could place the bulk electric system at an unacceptable risk of instability,
separation, or cascading failures; or
b. A requirement in a planning time frame that, if violated, could, under
emergency, abnormal or restorative conditions anticipated by the preparations,
directly cause or contribute to bulk electric system instability, separation, or a
cascading sequence of failures, or could place the bulk electric system at an
unacceptable risk of instability, separation, or cascading failures, or could
hinder restoration to a normal condition.

Medium Risk Requirement
a. A requirement that, if violated, could directly affect the electrical state or the
capability of the bulk electric system, or the ability to effectively monitor and
control the bulk electric system. However, violation of a medium risk
requirement is unlikely to lead to bulk electric system instability, separation, or
cascading failures; or
b. A requirement in a planning time frame that, if violated, could, under
emergency, abnormal or restorative conditions anticipated by the preparations,
directly affect the electrical state or capability of the bulk electric system, or
the ability to effectively monitor, control, or restore the bulk electric system.
However, violation of a medium risk requirement is unlikely, under emergency,
abnormal or restoration conditions anticipated by the preparations, to lead to
bulk electric system instability, separation, or cascading failures, nor to hinder
restoration to a normal condition.

Page 3 of 8 Comment Form — Proposed Violation Risk Factor SAR
Lower Risk Requirement
a. A requirement that, if violated, would not be expected to affect the electrical
state or capability of the bulk electric system, or the ability to effectively
monitor and control the bulk electric system. A requirement that is
administrative in nature; or
b. A requirement in a planning time frame that, if violated, would not, under the
emergency, abnormal or restorative conditions anticipated by the preparations,
be expected to affect the electrical state or capability of the bulk electric
system, or the ability to effectively monitor, control, or restore the bulk electric
system. A planning requirement that is administrative in nature.

Additional information on the Energy Policy Act of 2005 can be found at the FERC Web
site http://www.ferc.gov/legal/maj-ord-reg/fed-sta/ene-pol-act.asp; additional
information regarding NERC’s transition to the ERO can be found at NERC’s Web site
at http://www.nerc.com/about/ero.html.

With the foregoing in mind, the requestor would like to receive industry comments on
this SAR and to obtain the input of the industry prior to determining the final scope
and of the SAR. Accordingly, we request your comments included on this form, e-
mailed with the subject “Violation Risk Factor SAR Comments” by March 6, 2006.


Page 4 of 8 Comment Form — Proposed Violation Risk Factor SAR
Question 1: Do you agree there is a reliability need for specifying the relative
risks of each NERC standard requirement?

Yes
No
Comments
The IESO is in full agreement a need exists to specifically categorize the relative risk
to the interconnected bulk power system of each NERC requirement with which to
develop appropriate penalties or sanctions for violations. To not do so would otherwise
imply all standards have equivalent implication to the BPS even those administrative
in nature and would carry similar sanctions, if violated, which is, in our view,
indefensible.

Question 2: Do you agree with the scope and applicability of the SAR?

Yes
No

Comments
It is unclear from the SAR what exactly is being proposed. Is it a proposal to (a)
develop the matrix (or review and revise the initial set of risk factors), or, (b) to insert
the risk factors already assigned by the ESDS and CCMC (but hasn’t gone through
public comment and balotting) to the standards already developed and to be
developed over the next 5 years or both (a) and (b)? We see the need for industry
consensus on the risk factors before they are inserted into the standards. Hence, we
would support this SAR if the purpose is to cover at least (a), above.


Question 3: Do you agree with the definition proposed for “High”?

Yes
No

Comments
Given this definition, the risk levels assigned to some of the standard requirements
appear to be questionable. Hence, we strongly suggest that the industry be provided
the opportunity to review and revise as necessary the